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Ohio Deposition Hi-Jinks

Most people wouldn't have a hard time determining whether their office had a photocopier or not. You would think that the acting head of information technology for the recorder's division of the Cuyahoga County fiscal office should be able to answer the question. But in a recent deposition the existence or non-existence of an office photocopier was a source of much discussion. Some of the best banter:

Deponent: When you say "photocopying machine," what do you mean?

Questioning Attorney: Let me be -- let me make sure I understand your question. You don't have an understanding of what a photocopying machine is?

Deponent: No. I want to make sure that I answer your question correctly.

Deponent's Attorney: Dave, I'll object to the tone of the question. You make it sound like it's unbelievable to you that he wouldn't know what the definition of a photocopy machine is.

Questioning Attorney: I didn't ask him to define it. I asked him if he had any.

Deponent: When you say "photocopying machine," what do you mean?

Questioning Attorney: Let me be clear. The term "photocopying machine" is so ambiguous that you can't picture in your mind what a photocopying machine is in an office setting?